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Revised Total Coliform Rule: The New Standard of Compliance

U.S. EPA Training--Hosted by Rural Community Assistance Partnership (RCAP) – April 2018. Revised Total Coliform Rule: The New Standard of Compliance. Cindy Y. Mack, HQ RTCR Rule Manager US EPA, Office of Groundwater & Drinking Water/DWPD/Protection Branch Washington, D.C. Agenda.

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Revised Total Coliform Rule: The New Standard of Compliance

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  1. U.S. EPA Training--Hosted by Rural Community Assistance Partnership (RCAP) – April 2018 Revised Total Coliform Rule: The New Standard of Compliance Cindy Y. Mack, HQ RTCR Rule Manager US EPA, Office of Groundwater & Drinking Water/DWPD/Protection Branch Washington, D.C.

  2. Agenda National Implementation Challenges SDWIS Data Monitoring Requirements • Routine, Additional Routine, Increased, Repeat Level 1 and Level 2 Assessments • Multiple TT-triggers • Resetting the second level 1 TT trigger • Field Scenarios • Seasonal Systems • Start-up procedures • Reporting and Recordkeeping Requirements • Violations • Implementation Reminders • Special Evaluations • New systems and baseline monitoring • Implementation Products

  3. National Implementation Challenges Multiple TT-Triggers: How to calculate within a month and within 12-rolling months? How to apply state discretion to elevate assessments? Managing and Conducting Level 1 and Level 2 assessments • Reset provision [40 CFR 141.859(a)(2)] Managing failure among seasonal systems with completing start-up procedures and/or submitting certification.

  4. SDWIS-Fed DATA

  5. Violations TCR April 1, 2015 – March 31, 2016 RTCR April 1, 2016 – March 31, 2017 92% violations among PWS serving <1001 94% violations among PWS serving <1001

  6. RTCR –Violations by System Type (24,443 total violations) 67% of total RTCR violations 18K systems 83K systems 50K systems SDWIS/Fed data: April 1, 2016 – March 31, 2017

  7. RTCR – Violations for TNCWS serving <1000(16,249 total violations) SDWIS/Fed data: April 1, 2016 – March 31, 2017

  8. Monitoring Requirements • Routine, Additional Routine, Increased, Repeat

  9. Monitoring: Types of RTCR Compliance Samples Routine samples: • Collect each monitoring period “Additional” routine samples • For PWSs sampling less than monthly (e.g., quarterly, annual). Repeat samples: • Collect when a routine or repeat sample is TC+ • Dual Purpose GWR sampling: If the state adopted

  10. Frequencies: Routine Monitoring For NCWS GW < 1,000 people • Monthly • Quarterly • Annual • Seasonal systems (monthly unless State reduces, must meet specific criteria) CWS GW < 1,000 people • Monthly (State may reduce, if meet criteria) SW < 1,000 people • Monthly Any PWS serving >1,000 people • Monthly

  11. Frequencies: Increased/Reduced GW PWSs Serving ≤ 1,000 People 40 CFR 141.854(c)(1); 141.854(e); 141.854(f); 141.854(i)(2); 141.855(c)(1) & 141.855(d)

  12. Monitoring: Additional Routine Applicable to PWSs NOT monitoring monthly For PWSs monitoring quarterly or annually: • PWSs must collect at least 3 “additional routine” samples the month following 1 or more TC+ samples • Samples must be: • Collected at regular time intervals throughout the month or on a single day if taken from different sites • Collected consistent with the sampling siting plan • Used to calculate whether the TT trigger has been exceeded or an E. coli MCL violation has occurred 40 CFR 141.854(j) & 141.855(f)

  13. 40 CFR 141.858 -- Repeat monitoring requirements (a)(3) ….The system must continue to collect additional sets of repeat samples until either total coliforms are not detected in one complete set of repeat samples or the system determines that a coliform treatment technique trigger specified in § 141.859(a) has been exceeded as a result of a repeat sample being total coliform-positive and notifies the State. If a trigger identified in § 141.859 is exceeded as a result of a routine sample being total coliform-positive, systems are required to conduct only one round of repeat monitoring for each total coliform-positive routine sample.

  14. Monitoring: Repeat Samples For each routine TC+ = collect 3 repeat samples (a set) Location = original site, 5 connections upstream, 5 connections downstream, or alternative sample locations (fixed or criteria in SOP). Collect at least one round (3 repeats) for each routine TC+, even if PWS triggered an assessment earlier in the month.

  15. QUESTION: When does a PWS stop taking repeats? Routine Sample TC+ Repeat Sample TC+ If an assessment is triggered in the month, PWS can STOP collecting repeats for TC+ repeat samples. • Must collect at least 3 repeats for each TC+ Routine Sample PWS must take at least one round of repeat samples for each routine TC+ 40 CFR 141.858

  16. Monitoring: speciation E. coli testing • Any sample (i.e., routine or repeat) that is TC+ must be further tested for E. coli **Results of all routine and repeat samples must be included in the determination of whether an assessment has been triggered. NOTE: Failure to analyze repeat TC+ for EC = E.coli MCL violation

  17. Triggers to Increased Monitoring REMINDER Multiple TT-triggers in rolling 12 months leads to INCREASED Monitoring • [1]*State has the discretion not to consider monitoring violations in determining a transient NCWS’s eligibility to remain on or qualify for quarterly monitoring if the system meets the provision of 141.854(a)(4).

  18. Level 1 and Level 2 Assessments • TT-triggers • Multiple TT-triggers • Resetting the second level 1 TT-trigger • Field scenarios

  19. Treatment Technique Triggers: Level 1 Assessment Must consider all compliance samples (total number of routine & repeat samples) to determine Level 1 assessment trigger Results PWS Collects ≥ 40 Samples > 5.0% TC+ 141.859(a)(1)(i) Within 1 month Level 1 assessment < 40 Samples ≥ 2 TC+ samples 141.859(a)(1)(ii) Failure to take every required repeat sample after any TC+ 141.859(a)(1)(iii)

  20. Treatment Technique Triggers: Level 2 Assessment *Second Level 1 trigger within a rolling 12-month period Unless state determines a likely reason that the samples that caused the first Level 1 TT trigger were TC+ and has established that the PWS has corrected the problem. 2nd Level 1* 141.859(a)(2)(ii) 12 rolling months 12 rolling months Level 2 Assessment E. coli MCL violation 141.859(a)(2)(i) For PWSs on annual monitoring: a Level 1 trigger in 2 consecutive years 141.859(a)(2)(iii) 40 CFR 141.859(a)(2)

  21. Completing Assessment Forms: Assessor’s Responsibility Use professional judgment to complete forms Provide additional details to support conclusions Note when no sanitary defects are found Complete within 30 days of learning of trigger exceedance

  22. Submission & Review of Assessment Form State review assessments to determine if: • PWS identified likely cause of trigger and sufficiency of the assessment • PWS corrected the problem or has an acceptable schedule for correction 40 CFR 141.859(b)(4)(iv) Submit complete assessment form to the state Within 30 days of learning that trigger has been exceeded

  23. Timing of Corrective Action PWS must complete corrective action(s): • By the time assessment form is submitted, which is within 30 days of learning of the trigger OR • Within state-approved timeframe PWS must notify the state when each scheduled corrective action is completed when not fixed within 30 days of TT-trigger Either PWS or state can at any time request a consultation with the other party to discuss the assessment and the corrective action(s) 40 CFR 141.859(c) & (d)

  24. Corrective Actions Associated with Level 1 and Level 2 Assessments

  25. Common Causes of Contamination & Corrective Actions

  26. Common Causes of Contamination & Corrective Actions (cont.)

  27. Common Causes of Contamination & Corrective Actions (cont.)

  28. Corrective Actions and Simultaneous Compliance with other NPDWRs PWSs should be aware that actions implemented to comply with the RTCR (e.g., disinfection as a corrective action) may affect their compliance with other rules. For example: • Temporary disinfection and compliance with the DBP rules. • Effect of alkalinity and pH adjustments to comply with the LCR on disinfection efficacy • Effect of changes in the disinfectant residual on the corrosivity of water

  29. Discretionary Authority What is in the best interest of public health protection Resetting the second level 1 TT trigger. [141.859(a)(2) Elevating and managing multiple TT-triggers incurred within a month or in 12-rolling months.

  30. Reset -- 40 CFR 141.859(a)(2) Level 2 treatment technique triggers. (i) An E. coli MCL violation, as specified in § 141.860(a). (ii) A second Level 1 trigger as defined in paragraph (a)(1) of this section, within a rolling 12-month period, unless the State has determined a likely reason that the samples that caused the first Level 1 treatment technique trigger were total coliform-positive AND has established that the system has corrected the problem. (iii) For systems with approved annual monitoring, a Level 1 trigger in two consecutive years.

  31. Reset Interpretation of 40 CFR141.859(a)(2) To reset the 2nd level 1 TT trigger (within a rolling 12-month period) from Level 2 assessment to Level 1 assessment. The Primacy agency must have: • determined that the PWS has found sanitary defect (the likely cause) of the 1st Level 1 TT trigger; AND • PWS has corrected/fixed the sanitary defect before the next (2nd) level 1 TT trigger .

  32. Multiple TT-Trigger Scenarios What to do? Primacy agency discretion and Professional judgement

  33. Super City: CWS that serves 4,000 Collects 4 coliform samples per month -- one sample each week.- Week 1 & 2 Sample Results - May 3: PWS submits (to the State) a Level 1 assessment form and if sanitary defects found but not fixed, PWS provides timeframe to fix and gains state approval for timeframe. Level 1 141.859(a)(1)(ii) • An assessment is needed; • Use professional judgement and/or State discretion: • NOTE: This is not another level 1 trigger Depends on action required by State

  34. Super City: Week 3 Sample Results An assessment is needed; Use professional judgement and/or State discretion. NOTE: This is not another level 1 trigger. Depends on action required by State An assessment needs to be conducted to address the TC+ occurences. Expand the scope and area covered by the 1st assessment triggered (if assessment still ongoing) Escalate the level 1 Assessment to a Level 2 Assessment (if assessment still ongoing) Conduct a separate Level 1 or Level 2 assessment (if Level 1 assessment was completed)* *NOTE: A problem persists despite previous assessments, it would certainly be appropriate for the state to require an outside assessor. There may be something the system is missing that a fresh set of eyes may see. If an outside assessor has been used already, the state may want to require a different or more skilled assessor.

  35. Super City: Week 4 Sample Results An assessment is needed; Use professional judgement and/or State discretion. NOTE: This is not another level 1 TT- trigger Depends on action required by State • RECALL • In accordance with the RTCR, no MCL violations have occurred • A TT-violation occurs when: • A PWS exceeds a TT trigger for a Level 1 or 2 assessment and then fails to conduct the required assessment or corrective action within the specified timeframe (40 CFR 141.860(b)(1)). • A seasonal system fails to complete state-approved start-up procedure prior to serving water to public (40 CFR 141.860(b)(2)).

  36. High Point: GW NCWS, serves 1,000 - collects 1 sample per quarter June 21 (30 days from trigger): PWS completes assessment and submits (to the State) a Level 1 assessment form. If sanitary defects found but not fixed, PWS provides timeframe to fix and gains state approval for timeframe. Level 1 (1st) 141.859(a)(1)(ii)

  37. High Point: 1 sample per quarter Level 1 TT-triggered (2nd) =Level 2 Increase to MONTHLY monitoring: No additional routines in July 141.859(a)(1)(ii) July 10: PWS completes assessment and submits (to the State) a Level 2 form Quiz: How many repeats need to be collected? • July 11: Use Professional judgement • PWS must submit Level 1 assessment form by July 11 • conduct assessment as part of on-going Level 2 assessment; or • conduct separate Level 1 Level 1 TT-triggered (3rd) = level 1 assessment 141.859(a)(1)(iii)

  38. High Point: increased to 1 sample per month August 10: PWS completes and submits (to the State) a Level 2 form Level 1 TT-triggered (4th) =Level 2 assessment

  39. Break ! 10 minutes

  40. Seasonal Systems • Routine monitoring • Start-up procedures

  41. Seasonal Systems A seasonal system is a NCWS that is not operated as a PWS on a year-round basis and starts up and shuts down at the beginning and end of each operating season Examples include campgrounds, fairgrounds, golf courses, seasonal food service facilities and ski areas State may exempt seasonal systems from start-up procedure requirements only if the distribution system remains pressurized during the entire period that the system is not operating 40 CFR 141.2; 141.854(i)(3); 141.856(a)(4) & 141.857(a)(4)

  42. Seasonal Systems - Reduced Monitoring Routine monthly monitoring Exception: GW seasonal systems that serve <1000 persons may be reduced to quarterly or annual monitoring if the PWS: • Meets the quarterly requirements at 40 CFR 141.854(g) and for annual monitoring the additional requirements found at 141.854(h) • Has an approved sample sitting plan that designates the time period of monitoring based on site-specific consideration 40 CFR 141.854(i) for NCWS <1000 GW

  43. Start-up Procedures All seasonal systems must demonstrate completion of a state-approved startup procedure before serving water to the public States have the flexibility to determine what start-up procedures are appropriate for a particular system based on site-specific considerations States may require one or more TC samples as part of the required start-up procedures 40 CFR 142.16(q)(2)(vii); 141.856(a)(4)(i); 141.857(a)(4)

  44. Health Based Violations Source – GPRA 2017 Violations report; all PWS n=6808

  45. RTCR Health Based Violations 1A = E. coli MCL 2A = Failure to complete level 1 assessment 2B = Failure to complete level 2 assessment 2C = Failure to complete corrective actions 2D = Failure to complete seasonal start up procedures 2016 – 661 violations 2017 – 949 violations January 2018 Freeze - First 21 months of RTCR ~ 2 seasonal start-up periods

  46. RTCR Seasonal System Violations TNCWS incur the vast majority of RTCR health based violations: • failing to meet the seasonal start up procedures is the highest violation Based on two “start up periods”, roughly 9% of the ~18,300 seasonal systems have failed to complete seasonal start up procedures

  47. Reporting and Recordkeeping Requirements

  48. Reporting PWSs are required to report to the state the following: • Failure to comply: within 48 hours • Monitoring results: 10 days from month or compliance period, depends if detect or non-detects • EC+ routine sample: end of day/24 hours • EC MCL violation: end of day/24 hours • Treatment technique violation: within 48 hours • Completed assessment form: 30 days from learning of trigger • Completed corrective action: 30 days or State determined • Certification of completion of state-approved start-up procedures for seasonal systems: before serving to public

  49. Recordkeeping PWSs are required to keep records of the following within a required timeframe: • Monitoring results • Assessment forms and documentation of corrective actions completed • Repeat samples taken that meets state criteria for extension of 24-hour period for collection • Copies of PN issued • Certifications • Sample siting plans

  50. Violations

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